Archive for Information

NHASA Fall Meeting Notice

Please follow the link below to your invitation to our Fall Education Meeting.  Hope to see you there!!

Fall 2014 meeting

Happy Fall!

Your Inpute is Needed Regarding CMS Proposed Rule

Good Afternoon,

We are emailing today because your input is needed in response to the Centers for Medicare & Medicaid Services (CMS) proposed ASC reimbursement rates for 2015. ASCA will once again submit comments raising industry-wide concerns, but it is important that CMS hear from individual centers and state associations as well.

According to the proposed rule, ASCs would receive an effective average update of 1.2 percent based on the Consumer Price Index for All Urban Consumers (CPI-U), while hospital outpatient departments (HOPDs) would receive an effective increase of 2.1 percent based on the hospital market basket. This would continue the troubling trend of diverging payments, and result in HOPDs receiving 81 percent more next year to perform the same procedures that are performed at ASCs. The first document attached is a sample comment letter advocating for ASC payments to be updated based on the hospital market basket to stop this growing disparity in payments.

With respect to the quality reporting program, CMS is proposing to make ASC-11, Cataracts — Improvement in Patients Visual Function within 90 Days Following Cataract Surgery, a voluntary measure. ASCA has worked hard to remove this as a mandatory measure, as it is inappropriate as a facility measure. The second letter attached is a sample comment letter thanking CMS for proposing to no longer require the reporting of this measures for the ASC quality reporting program. The more support CMS receives for this proposal, the more likely it will be finalized, so please take a few minutes and send your letter today.

Also, as a reminder, the agency proposed to add 10 new spine procedures to the ASC list of payable procedures for 2015. The third letter attached is a sample comment letter requesting the addition of these procedures to the ASC payable list.

The final attachment includes other basic sample language that could be incorporated into any comment letter. While we provide you with draft language because we know how busy you are, the most persuasive letters will also include your individual details regarding how the proposed changes will impact your center.

CMS Draft Template Letter

2015 Comment Letter Talking Points

CMS Draft Template Letter_CPI-U

CMS Draft Template Letter_ASC-11

Click here to submit your comment on the proposed changes. Comments are due Tuesday, September 2 at 5 pm ET.

For more information, contact Kara Newbury at


ASCA Reports: “Victory for ASCs: CMS Removes Burdensome Radiologist Requirement”

As reported by the ASC Association…

The Centers for Medicare & Medicaid Services (CMS) has removed the provision in the Conditions for Coverage (CfCs) requiring ASCs to have a radiologist on their medical staff. This change was part of a larger pre-published final rule released yesterday entitled, Medicare and Medicaid Programs: Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction. ASCA has long advocated for this change noting that requiring ASCs to have a radiologist on staff does not make sense given that radiologic services in an ASC are generally limited to intra-operative guidance that does not require interpretation by a radiologist. Additionally, ASCs have reported difficulty in finding radiologists that are willing to be part of their medical staff.

Instead of requiring a radiologist on staff, the new language, found at §416.49(b)(2), states:

“If radiologic services are utilized, the governing body must appoint an individual qualified in accordance with State law and ASC policies who is responsible for assuring that all radiologic services are provided in accordance with the requirements of this section.”

The language CMS initially released when the rule was proposed in 2013 would have stated that instead of requiring a radiologist to be on staff, a doctor of medicine or osteopathy on the ASC’s medical staff would be charged with supervising the provision of radiologic services in an ASC. In its comment letter responding to this proposed language, ASCA raised concerns that the proposed requirement was not that different from what was already in place. ASCA requested language giving the governing body authority to appoint the appropriate individual if radiologic services were needed in the facility.

“We are pleased that CMS has responded to our request for a common sense policy pertaining to radiological services in ASCs,” said William Prentice, chief executive officer of the Ambulatory Surgery Center Association. “We look forward to continuing an open dialogue with CMS to identify and remove other burdensome requirements that hinder our ability to serve patients in the most efficient manner possible.”

CMS estimates that the change will save ASCs $41 million annually.

The rule is scheduled to be published on Monday, May 12, 2014, and the change becomes effective 60 days after publication. Click here to view the final rule. The relevant portion begins on page 16.

ASCA will continue to work with CMS to remove other regulatory requirements that are burdensome to ASCs. For more information, please contact Kara Newbury at

Medicaid Enhancement Tax and ASC’s!!!

Hospitals are well aware of the status of proposals relative to attempts to resolve the MET (Medicaid Enhancement Tax) issue but as ASC administrators, physicians and owners, the NHASA feels you should know as well.

There are three current amended proposals with regards to the MET (Medicaid Enhancement Tax) floating but the one that is of particular concern would be the amendment offered by  Representative Hess (attached) that seeks to expand the base of the MET and would include ASC’s.

The situation is extremely fluid with a lot of moving parts and final resolution will require cooperation of all stakeholders.

Please contact your Representatives and voice your concern over Representative Hess’ proposal to include Ambulatory Surgery Centers, who already as small business’ pay a Business Enterprise Tax.

Click on the link below to read the proposed ammendment.

Hess Amendment to SB 369-FN

There is strength in numbers!



Feedback Requested!!

Good Afternoon All,

We are asking for feedback on the following:


Commenting on Changes to Life Safety Code

CMS announced last week that it intends to adopt the National Fire Protection Association’s (NFPA) 2012 editions of the Life Safety Code (LSC) and the Health Care Facilities Code (HCFC). According to the CMS fact sheet, adopting the newer edition of the LSC “would reduce the burden on health care providers because the 2012 edition of the LSC is aligned with international building codes, and therefore implementation of this edition would make compliance across codes much simpler for Medicare and Medicaid-participating facilities.” Currently, CMS employs the standards in the 2000 edition of the LSC.


ASCA will be submitting comments on behalf of the industry, and appreciate any feedback you or others from your organization may have on the proposed changes. The deadline to submit comments is June, 16, 2014. The proposed rule can be found here. If you have questions, contact Kara Newbury at


Registration for June Fly-In

The June ASCA Capitol Fly-In is less than two months away, June 17-18 in Washington D.C., offering the rare opportunity to speak directly with your members of Congress.


Register now:

New Hampshire Action Coalition

Dear Nursing Colleague,


You are being invited to take part in a survey sponsored by the New Hampshire Action Coalition to identify the extent to which nurses are serving in leadership roles on Boards of Trustees or Boards of Directors.   Additional information about the work of the Action Coalition can be found by clicking the survey link.


Your input can help us better understand our NH nurses current involvement within our local, state, and national organizations.


Please respond by May 16th 2014. We estimate that it will take you approximately 5 minutes to complete the survey.


Simply click on the link below or cut and paste the entire URL into your browser to access the survey:


Your input is very important to us and will be kept strictly confidential (used only for the purposes of the NH Nurses Coalition project)


Thanks for your participation


“The Leadership Pillar workgroup of the New Hampshire Action Coalition”

Patricia Sweezey MS RN

Brian Pinelle MBA, MSN, RN

Linda J. von Reyn, PhD, RN

Carol Long MS, RN

Elaine Cartier BSN, RNC

Heather Wilson- Labbe, MBA, BSN, RN, CWOCN

Physicians’ Payments Will Be Cut 24% If Your Senator Does Not Vote For S. 2110

As you are probably aware, the payments for some procedures performed in ASCs are linked to the physician fee schedule and therefore have been subject to potential payment cuts under the Sustainable Growth Rate (SGR) formula. For more than a decade, Medicare providers have been subject to the constant threat of substantial payment cuts due to the SGR. Next week, the Senate may consider S. 2110, legislation which would repeal the SGR and replace it with a new payment system.
For the first time, there is bi-partisan, bi-cameral agreement on a new payment system to repeal and replace the SGR once and for all. Now is the time to make your voice heard. Please contact your Senator and ask them to support the Senate Finance Committee’s SGR repeal legislation. Without this legislation, physicians and many ASC procedures face a 24% payment cut in the near future and lack of an agreement could threaten access to care for Medicare patients nationwide.
On a final note – in addition to bringing stability to the Medicare payment system, the legislation also includes important transparency language that would require the Centers for Medicare and Medicaid Services (CMS) to disclose why they deny procedures from being performed in an ASC setting.
Take action now.

As published by ASCA’s Steve Miller, Director of Government and Public Affairs Ambulatory Sugery Center Association


Support SB 250


SB 250 seeks to authorize ambulatory surgical facilities to keep patients for up to 48 hours from the time of admission. Current law requires that after 24 hours the patient shall be either discharged or transferred to another health care facility.

 Patient Choice            Lower Health Care Costs              Lower Infection Risks

 ASC have demonstrated quality of patient care services and high level of satisfaction.

  Why 48 Hours: driven by the demand for total joint procedures or other procedures requiring longer recoveries for pain control 

  • 48 Hours needed for pain management
    • Procedures take longer but real concern is the need to properly managed post surgery pain


  • Patient experiences are all very positive for partial joints and other ASC procedures
  • Patients want and should have the option of whole joint replacement
  • Why should Government be a barrier to individual health care choice


  • Healthcare costs today are an enormous challenge
  • Here is a proven way to control some of the costs and give patients a choice
  •  Lower costs of ASC procedures is well documented


 ASC have documented lower risks for infections  

  SB 250 is an opportunity.

 An opportunity to eliminate a government barrier to allow patients greater choice over their own care.

 An opportunity to significantly control and lower an individual as well as system health care costs

An opportunity to lower patient’s risks. We know and have seen health care does not have to mean hospital care.

It is time for us to ralley for the support of this bill.  Please contact your legislators and ask them to support this bill.  Ask the physicians/surgeons in your ASC to contact them as well.  There is strength in numbers.

Education Update

Thank you to all who attended Wednesday evening’s meeting. As promised, here is Kara Newbury’s slide presentation.  Click on the link below to view the powerpoint presentation.

NHASA Presentation Kara Newbury 2.12.2014

Please let me know if there are any issues uploading this file and I will email it to you directly.


Quality Net Information

Sam from Hillside ASC spoke with QualityNet help desk and they referred her to FMQAI regarding the Measure ID#: ASC-11 (cataract). 

To sum it up, you can select from one of the four questionnaires listed on page 27 of the Centers for Medicare & Medicaid Services, Ambulatory Surgical Center Quality Report Program version 3.0a. 

 Regardless of which questionnaire you choose, you will need to capture the data both pre and postoperatively on all patients that meet the description listed by CMS for this measure (pretty much every patient aged 18 or older having cataract surgery).  

We will need to collect the data from April 1st through the 31st of December 2014. 

Then we will have until August 1st to complete the web-based measure on QualityNet. 

We will be manually entering a denominator (total number of patients) and a numerator (total number of patients that had improved visual function).  So no importing of excel spreads or anything like that.  Just two numbers to enter.  They are still encouraging the surgeons office be the ones who collect the data as they have the strongest system for visual function assessment.  They also suggested the VF-8 form as it is the shortest with only 8 questions to be answered. 

The NHASA wishes to thank Sam for this information.  Please feel free to post any comments or additional information that you may wish to share with everyone.